There was no reasonable expectation of privacy in jail telephone calls for pretrial detainees because the inmates were warned. “To the extent that defendant argues that the admission of the phone calls violated his rights because he was being held on bail rather than serving a sentence, the Court of Appeals has yet to differentiate as to the applicable constitutional standard as between phone calls placed by those individuals held on bail and those who are serving sentences.” People v. Brown, 2021 NY Slip Op 03633, 2021 N.Y. App. Div. LEXIS 3739 (3d Dept. June 10, 2021).
Defendant’s Brady claim that after acquired information would have changed the result of his suppression motion is denied because it wouldn’t. State v. Baird, 2021-Ohio-1962, 2021 Ohio App. LEXIS 1925 (8th Dist. June 10, 2021).*
“In this case, the evidence is admissible as it would have been discovered, regardless of whether TPD officers cleared the firearms and ammunition as a community caretaking function or pursuant to a protective sweep, because two TPD procedures mandated the inventory of the vehicle’s contents.” United States v. Ahaisse, 2021 U.S. Dist. LEXIS 108900 (N.D. Okla. June 10, 2021).*
The CI’s information was specific except as to dates, but the officer had “other channels” of information to corroborate. That was probable cause. United States v. Dismukes, 2021 U.S. Dist. LEXIS 108920 (N.D. Ind. June 10, 2021).*